Pre-deposit waiver for coil slitting and sheet cutting where the process was found prima facie not to amount to manufacture.

Waiver of pre-deposit and stay of recovery were granted where slitting steel coils into narrower coils and cutting them into sheets was held to present a strong prima facie case that the activity did not amount to manufacture. The Tribunal relied on the department's own materials, including a Trade Notice and deliberations of Chief Commissioners, which indicated uncertainty or non-treatment of the process as manufacture. On that basis, duty and penalty deposit was waived and recovery was stayed.

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Issues: Whether the applicant was entitled to waiver of deposit and stay of recovery in relation to duty and penalty arising from the processes of slitting steel coils into narrower coils and cutting them into sheets.

Analysis: The Tribunal found a strong prima facie case that the activity of making sheets from coils was not manufacture, and that the department's own materials, including a Trade Notice and the conference of Chief Commissioners' deliberations, indicated uncertainty or non-treatment of the processes as manufacture.

Outcome: Deposit of duty and penalty was waived and recovery stayed.

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